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Fixing consultation

Interesting news today from the Cabinet Office, who issued their three-page Consultation Principles (embedded below), with the accompanying explanation:

The Government is improving the way it consults by adopting a more proportionate and targeted approach, so that the type and scale of engagement is proportional to the potential impacts of the proposal. The emphasis is on understanding the effects of a proposal and focussing on real engagement with key groups rather than following a set process.

The key Consultation Principles are:

departments will follow a range of timescales rather than defaulting to a 12-week period, particularly where extensive engagement has occurred before;

departments will need to give more thought to how they engage with and consult with those who are affected;

consultation should be ‘digital by default’, but other forms should be used where these are needed to reach the groups affected by a policy; and

the principles of the Compact between government and the voluntary and community sector will continue to be respected.

The new Consultation Principles will be promoted within Whitehall now, and the public will begin to see the new guidance take effect in early autumn 2012.

Overall, I’d say it’s quite an encouraging document – with a focus on sensible timescales, more thought applied to making the consultation materials accessible, considering whether informal online engagement might substitute for formal processes in some cases, and being more transparent about how the feedback is used. I worry though that civil servants may read the document simply as meaning that ’12 weeks doesn’t apply any more’ – perhaps the one bit of the Consultation Code which has been familiar to every civil servant working on a consultation. Similarly, ‘digital by default’ is at risk of becoming a weasel phrase akin to ‘evidence based policymaking’ or ‘social marketing’ which can be met with a nod to a SurveyMonkey response form or a tweeted launch.

With that in mind, here’s some of the principles I’d like to see adopted here:

Be clear about what’s for debate: explain clearly what policy is already decided, or what the constraints on options may be

Write fewer, better questions people can and want to answer: use clear language, not dumbing down material for specialists, but consider summarising for other groups. Don’t simply ask people if they agree with the proposed solution on X.

Ask different audiences different questions: don’t expect all service users to comment on econometric models; welcome simple indications of priorities, patient or customer stories, comments and ideas alongside traditional submissions from lobby groups.

Use market research, operational and analytical data alongside consultation data: representative opinion data isn’t marketing spin, and behavioural data is sorely underused too. Don’t shape policy simply according to the voices of those who showed up the consultation.

Join the conversation in places where people discuss these issues: take the consultation into online communities, shopping centres, staff canteens and email lists. Have the courage and personality to become an active member, empathise and engage.

Help people to stay informed (and tell them if you haven’t yet decided something): some people will want to know where this came from, where it’s going, and what happened as a consequence. Use simple tools like email, blogs and social media to tell the story of the consultation and its outcomes.

Analyse responses intelligently: plan your analysis before the consultation launch, including how you will process and report on responses. Consultations aren’t votes: weight responses intelligently but with an open mind.

Published

This is all prudent stuff but we shouldn’t lose sight of some important structural problems with consultation.

Even in good consultation there is a clear power relationship “we have the power, we will make the decision, we would like to know what you think”. It would be great to see guidance that included steps from the ladder of participation
– “Can we allow citizens to make the whole of this decision?” If not then:
– “Can we delegate some aspects of this decision?” If not
– “Can we develop this in partnership with citizens?” If not
– “Can we consult before shaping this decision?”

As anyone who has ever tried to analyse consultation reports realises it is a process riven with subjective judgements. Different responses may carry different weightings: Barnados would expect to be taken more seriously on a consultation over looked after children than me. But I might make a quite brilliant point that no-one has ever thought of and so a sensible civil servant will highlight this. And of course there are political and financial realities that will affect how sensible any individual response appears internally. This may not look the same from outside the organisation.

Some of this subjectivity can be reduced by the introduction of evidence, showing how policy proposals are based on objective data (and publishing that data). And weighting responses based on an assessment of evidence rather than professional standing.

And the bits that cannot be reduced could at least be made explicit. Explaining that this response was dismissed because it ran counter to the political direction of the government and that this one was used because it came from one of the country’s leading experts in the field would shine a light into a very murky aspect of work.

Steph, question for you. Do you think the assumption that writers deliberately make questions difficult to understand so as to limit the number of responses is right or wrong?
(I have my own views having spoken to writers myself now but I’m curious to know yours)

No, it’s not a conspiracy. They’re just intelligent people thinking complex thoughts, and sadly not expressing them very well as questions. That said, there is a niche audience of professionals happy to engage with those complex thoughts as written, but they’re not the full extent of the potential valid audience for a consultation. It’s one of the reasons I suspect Inside Government have one of the toughest jobs around.